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The agreement requires customers to comply with U.S. export controls and OFAC regulations, and states that upon termination for export control breach, the customer loses all rights to Customer Content, which Figma may immediately quarantine, delete, or remove. Figma may suspend access or terminate the agreement to comply with applicable legal obligations.
This analysis describes what Figma's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes that a termination for export control breach results in forfeiture of all rights to Customer Content held by Figma, with immediate deletion or quarantine authorized. This is a materially distinct consequence compared to standard termination provisions, which include a 30-day post-termination retrieval period for Customer Content. The loss of Customer Content upon export control termination creates significant data loss risk for affected customers.
Under this clause, if the agreement is terminated due to an export control violation, the customer forfeits all rights to Customer Content and Figma may immediately delete or quarantine that content without the 30-day retrieval period available under standard termination. Figma may also suspend access immediately based on its own compliance obligations under OFAC.
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"Customer must comply with all applicable Export Controls in Customer's access to and use of the Figma Platform and Customer Content. Customer will not access or use the Figma Platform, export, re-export, distribute, assign, or otherwise engage in any transaction relating to the Figma Platform or any Customer Content in violation of Export Controls. For the avoidance of doubt, Figma may take measures required by law or governmental authority to comply with its obligations under Export Controls and OFAC (such as suspending access to the Figma Platform, terminating this Agreement, or blocking the relevant Customer Content). [...] Notwithstanding the foregoing, upon termination of this Agreement for breach of Section 9.12 (Export Control), you lose all right, title, and interest to Customer Content, and Figma may immediately quarantine, delete, or remove Customer Content, and immediately suspend your use of and access to the Figma Platform.Excerpt from Figma's Terms of Service (Superseded URL)
(1) REGULATORY LANDSCAPE: This provision directly references U.S. Export Administration Regulations and OFAC sanctions administered by the U.S. Department of the Treasury. The Bureau of Industry and Security (BIS) within the Department of Commerce enforces the Export Administration Regulations. Violations of OFAC sanctions carry civil and criminal penalties under 50 U.S.C. Chapter 35. (2) GOVERNANCE EXPOSURE: High for customers operating internationally or in restricted sectors. The content forfeiture provision upon export control termination is operationally significant because it eliminates the standard 30-day post-termination Customer Content retrieval window and authorizes immediate deletion. (3) JURISDICTION FLAGS: Customers operating in or with counterparties in OFAC-designated jurisdictions face heightened exposure. Non-U.S. customers should assess whether their use of Figma (a U.S. company's platform) subjects them to U.S. export control obligations. Customers with OFAC-sensitive business activities should conduct a specific compliance review. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should assess whether their use of Figma for projects involving international counterparties or sensitive technology requires export control compliance procedures. The agreement places compliance responsibility entirely on the customer, with Figma reserving suspension and termination authority as enforcement mechanisms. (5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm whether their organization or any Authorized Users are located in or conducting business with OFAC-designated countries or persons. A periodic review of the OFAC Specially Designated Nationals list against Authorized User accounts may be warranted for organizations with global workforces.
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This provision establishes that a termination for export control breach results in forfeiture of all rights to Customer Content held by Figma, with immediate deletion or quarantine authorized. This is a materially distinct consequence compared to standard termination provisions, which include a 30-day post-termination retrieval period for Customer Content. The loss of Customer Content upon export control termination creates significant …
Under this clause, if the agreement is terminated due to an export control violation, the customer forfeits all rights to Customer Content and Figma may immediately delete or quarantine that content without the 30-day retrieval period available under standard termination. Figma may also suspend access immediately based on its own compliance obligations under OFAC.
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